The smell of marijuana came from the passenger compartment, and the court finds that the probable cause that it creates is limited to the passenger compartment under the automobile exception. United States v. Chavez, 2018 U.S. Dist. LEXIS 107695 (N.D. Cal. June 26, 2018), reconsideration granted, and suppression denied, 2018 U.S. Dist. LEXIS 150293 (N.D. Cal. Sep. 5, 2018) (because a gun was found inevitably; see post 9/8/18).
Plain feel of crack cocaine during a strip search justified its seizure. State v. Evans, 2018 N.J. LEXIS 870 (June 28, 2018).